It seems like once every week or two I get a call or email from someone asking me if I’d help clarify for them OSHA’s requirements on labeling of in-house containers and secondary containers per the revised Hazard Communication standard. Apparently many people think that OSHA now requires all in-house containers be labeled with the pictograms and other information adopted from the Global Harmonized System of Classification and Labeling of Chemicals (GHS), and that OSHA no longer allows the use (some even say they “outlaw” the use) of other hazard labeling systems such as those created by the National Fire Protection Association (NFPA) and the Hazardous Materials Identification System (HMIS).
In actuality, it is only those containers shipped by manufacturers, importers, and distributors that are required by OSHA’s updated Hazard Communication standard to be labeled with all the GHS-related information (specifically, a product identifier, signal word, hazard statement(s), pictogram(s), precautionary statements, and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party). But when it comes to labeling of in-house containers . . .
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